Advocacy Archive

ASTCT is working on your behalf in Washington, DC to address the policy issues that are important to you. Below is an archive of news articles and columns covering ASTCT's recent advocacy activity.  

Helpful Coding Links  

Visit ASTCT's Coding and Reimbursement page for . . .

Care Management Visits, Codes and Appropriate Billing  

CAR-T Coding and Reimbursement webinar 

Information about the ICD-10-PCS code for CAR T that will go into effect on October 1, 2017

and more . . . click here.  

Latest Press Releases & Announcements 

Dec. 2017 - The new hematopoietic cell transplantation and cellular therapy specialty code is C9.  

Nov. 2, 2017 - ASTCT sent two letters to CMS: a Request for New MS-DRGs for CAR-T Therapy for FY 2019 and a Request for CMS to Invoke CMMI Authority for CAR-T Drug Reimbursement for Medicare and Medicaid Patients

Oct. 30 2017 - new resourceCAR-T Coding Guidance Document

WEBINAR Nov. 2: on CAR-T Coding and Reimbursement 

ASTCT Goes to Washington! - September 2017 

ASTCT Opposes the Graham-Cassidy Proposal - September 20, 2017 

In September, the ASTCT sent three letters of importance to the Centers for Medicare & Medicaid Services on CAR-T reimbursement, OPPS and PFS.

In June 2017, our team worked together to coordinate a response to the latest proposed Medicare inpatient rule changes, yielding a 12-page response that covered financial issues critical for our Society, ranging from potentially decreased inpatient reimbursement to impacts on emerging T cell immunotherapies.  

ASTCT Urges Senate to Revise ACHA - Ensure Access to Care - May 2017 

ASTCT Comment Letter on the ICD-10 coding proposal regarding Chimeric Antigen Receptor T Cell therapy (CAR-T) - April 2017 

ASTCT Statements on American Health Care Act and Proposed NIH Budget Cuts  - released March 17 and 23, 2017 

ASTCT Official Statement Opposing Executive Order on Immigration - released Jan. 30, 2017 


Policy Perspectives
StephHeadShot_2016_Farnia_sm.jpgA monthly column by Stephanie Farnia, ASTCT Director of Health Policy and Strategic Relations 

February 2018 

The Institute for Clinical and Economic Review (ICER) has been moving through a process of evaluating the cost effectiveness of CAR-T.  The ASTCT has submitted a comment letter on the draft evidence report as an identified stakeholder and Dr. Komanduri will be participating as part of an expert panel when the documents are up for a vote on March 2.  A few selected Tandem highlights: Tandem can be overwhelming. There are always 18 things happening at once and your calendar is packed from 6am-9pm. All of the sessions will be valuable, but I try to scour the various tracks to find those most key to what I need to know in my position. I’m sharing some of that with you below in case it’s is of interest.  READ MORE.  

January 2018 

As I have begun stumbling through my Tandem preparations, it became clear that while we do have new areas of access and reimbursement issues to pursue, much of our focus this year will be on finishing what we have started – i.e. moving current initiatives from the half-way point to the finish line.  A brief summary of these focus areas is below and I will highlight sessions at Tandem that plan to discuss these issues in more detail in February’s column. Finally – I listed a few articles and podcasts that I found particularly helpful recently at the end of the column.   READ MORE.  

December 2017 

“Winter is coming…” I have never seen Game of Thrones, but am told this phrase is an ominous bit of foreshadowing. In the slightly less bloody realm of healthcare policy, winter is instead a brief and welcome respite from the Medicare rule-making cycles that dominate the calendar between April and November. It also affords a bit of time to reflect on accomplishments of the year to date, prioritize issues left undone and start to develop plans to tackle those concerns.  READ MORE.  


November 2017 

As you have read in previous columns, the approval of CAR-T products in 2017 has created several substantial streams of work on the reimbursement and coding side of the world. For the last several months, a small team has been working to assess which codes currently available in the various reimbursement systems would be useable for billing CAR-T services and, in a complementary fashion, to establish which new codes would need to be created. (This column includes the new resource: CAR-T Coding Guidance Document) READ MORE.

October 2017
September was an enormously busy month for ASTCT policy activities. Comment letters were submitted to CMS, we hosted our first Hill Day, spoke with our industry partners at the Corporate Council event and continued to work our way through the wacky world of reimbursement coding. READ MORE.  

September 2017
It has been a much busier summer in the health policy world than usual – multiple comment periods for CMS proposed annual policy rules, uncertainty around the Affordable Care Act repeal efforts and a couple of ‘out of left field’ issues I’m blaming on eclipse-driven zaniness. In large part, summer in the policy area is always reactionary – anticipating proposed rules and responding as needed when they are released – but this year felt particularly so... There are numerous updates to share this month; I will divide them up between HCT and CAR T for easy future reference. READ MORE.  

August 2017
I am turning the column over this month to a guest co-author – Dr. James Gajewski – who is a long-time ASTCT volunteer in relation to reimbursement issues and currently serving as the Practice Policy Consultant to the Society. The focus of this month’s column is on a series of relatively new codes for use in billing time spent in clinic with patients. READ MORE

July 2017
I’ll start this month’s column with a resounding THANK YOU to all of you that took the time to really understand the issues with the CMS FY18 Inpatient Prospective Payment System (IPPS) Proposed Rule. More than 44 transplant centers (TC) commented with a total of 138 TC comments. The highest volume TCs were Dana Farber, University of Kentucky and University of North Carolina. Also, on June 20, CMS released the proposed rule for the Quality Payment Program (QPP). This column covers what you need to know about the "CMS Quality Payment Program – Year 2 Proposed Rule."  READ MORE.  

June 2017  
May was an extremely busy month here in the health care policy camp and, as such, I am going to try to fit several updates within the June column: IPPS Comment Period Ending Soon; Payers Misinterpreting CMS Commentary of HCT Site of Care; HRSA Revises Process for SCTOD Contract; and CMS Issues Initial Guidance for HCT Specialty Designation. Some of these issues will receive a more substantial write-up in future months – in the meantime, please contact me if you need more information on any particular item. READ MORE

May 2017
April kicks off the beginning of the Medicare (CMS) rule-making season. As a Federal Agency charged with the role of implementing health care legislation, CMS enters a lengthy process each year of creating the new Inpatient Prospective Payment System (IPPS) Final Rule – a set of very detailed instructions, payment procedures and calculations for the upcoming Fiscal (FY) or Calendar Year (CY).  ...Each year, the ASTCT and NMDP partner to attempt to get health professionals and transplant programs to comment on the proposed rule. This is not a fruitless endeavor – the positive changes you have seen in your reimbursement, including the splits to the Autologous and Allogeneic DRGs and the dramatic increase in the outpatient payment rate for 2017, are due to the efforts of yourselves and your colleagues in sending comments to CMS. Due to the potential impact of the proposed changes for FY18, we will need all of you to comment on the issues of concern this year. READ MORE.  

April 2017 

"The (Withdrawn) American Health Care Act" -- There is a unique challenge associated with writing a monthly column on policy issues, as these issues move so quickly in seasons of active debate that hours of writing time evaporate in an instant. My original due date for this piece was the night before the expected vote on the American Health Care Act (AHCA), which was withdrawn from the floor on Friday, March 24. As I was planning to completely erase this column and move on to something else, it occurred to me that while the AHCA as it was drafted no longer seems an imminent threat, it is still useful to understand the impact it would have had on our field. READ MORE.

March 2017 

In 2016, the National Marrow Donor Program (NMDP)/Be The Match and ASTCT partnered on a targeted campaign around the issue of Medicare reimbursement. There were multiple letters placed in various parts of the country, three of which were authored by Krishna Komanduri, M.D. (Miami Herald), Fred LeMaistre, M.D. (MedPage Today), and Navneet Majhail, M.D. (Cleveland Sun). Each of these articles was tracked for “impressions” – the number of individuals that interact with it in some manner, whether that be posting to Facebook or Twitter or simply sending a copy of the article via email to another individual. READ MORE

February 2017 
New Codes for Billing Work Outside of Patient Visits:  Evaluation & Management (E/M) coding refers to billable services from provider-patient encounters that are submitted to a patient’s insurer or payer. E/M services have been historically limited to the time during which the physician was physically in the room with the patient, discussing and taking action on any relevant concerns. Any additional care management that took place before and/or after the visit was not considered billable.  READ MORE.

January 2017
Alphabet Soup: MACRA, MIPS and QPP. I know what you’re thinking: “Do I care about any of these programs?” Yes, you do. You care about them in the same way that you care about broccoli and spinach – not very appealing, but supposedly good for you. The bottom line is that by 2022, 9% of your billed Medicare revenue will be at risk, based on your participation and score in the program.  READ MORE.



See also the Pharmacy SIG Advocacy and Policy Toolkit.